03.14.07: Withdrawn

03.14.07 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You operationalize it by documenting that it is withdrawn, mapping any legacy control intent to current Rev. 3 requirements where applicable, and retaining evidence that your CUI compliance program tracks framework changes and assessment scope. ¹

Key takeaways:

• Treat the 03.14.07: withdrawn requirement as a governance and traceability task, not a technical implementation task. ¹
• Preserve assessor-ready documentation: “withdrawn” disposition, rationale, and crosswalk to replacement/related requirements in your control set. ¹
• Prevent audit friction by updating SSPs, control matrices, and evidence plans so 03.14.07 cannot show up as an “unmet control.” ¹

A withdrawn requirement is a practical trap for compliance teams: it can show up in legacy spreadsheets, inherited SSP language, third-party questionnaires, or automated GRC libraries, then trigger “missing evidence” findings during internal reviews. For NIST SP 800-171 Rev. 3, 03.14.07 is explicitly marked withdrawn, which means your job is not to deploy a new safeguard. Your job is to prove you recognized the withdrawal, removed the requirement from your implementation scope, and maintained traceability so assessors and stakeholders understand what changed and why. ¹

For federal contractors and other nonfederal organizations that handle CUI, this is more than paperwork hygiene. A control catalog with stale requirements creates inconsistent assessments, muddles POA&Ms, and wastes time during audits because your team ends up debating scope instead of demonstrating operating controls. The goal of this requirement page is to help you close that gap quickly: set a clear disposition for 03.14.07, align your artifacts (SSP, policies, control mapping, evidence collection), and prevent future reintroduction through third-party risk workflows or template reuse. ¹

Regulatory text

Regulatory excerpt: “NIST SP 800-171 Rev. 3 requirement 03.14.07 (Withdrawn).” ¹

Operator interpretation of the text: NIST has removed 03.14.07 from the Rev. 3 requirement set. You should not claim implementation of a control “for 03.14.07” because there is no longer a requirement statement to implement. Instead, you must:

• Record the requirement’s status as Withdrawn in your control inventory and SSP traceability. ¹
• Ensure any legacy Rev. 2-era mapping or internal control that previously aligned to 03.14.07 is either mapped to current Rev. 3 requirements or documented as “no longer required,” based on your environment and risk decisions. ¹
• Maintain evidence that you manage framework changes and do not allow withdrawn requirements to generate gaps, testing exceptions, or POA&Ms. ¹

Plain-English interpretation (what 03.14.07 means in practice)

03.14.07: withdrawn requirement means: “This line item exists for reference, but it is not a current compliance obligation in Rev. 3.” Your operational requirement is governance: keep your compliance system accurate and assessor-ready.

Treat “withdrawn” as a controlled decision point:

• If your program previously tracked 03.14.07, you need a clean crosswalk note that explains what replaced it (if anything) or where the underlying security objective is now covered.
• If your tooling still shows it, you need to correct the source library, not generate busywork evidence.

A good outcome is simple: anyone reviewing your NIST SP 800-171 Rev. 3 alignment can see 03.14.07, see it marked withdrawn, and see that nothing is missing because nothing is required for that identifier. ¹

Who it applies to (entity + operational context)

This applies to:

• Federal contractors and nonfederal organizations handling CUI that use NIST SP 800-171 Rev. 3 as their security requirements baseline for in-scope systems and enclaves. ¹
• Compliance owners and operators: CCOs, CISOs, ISSMs, GRC leads, internal audit, and system owners who maintain SSPs, control matrices, and evidence repositories for assessments against NIST SP 800-171 Rev. 3. ¹

Typical operational touchpoints where 03.14.07 shows up:

• SSP requirement tables copied forward from older templates.
• Control mapping sheets used for internal audits.
• GRC platform control libraries that were imported once and never refreshed.
• Third-party questionnaires where a prime or customer references an outdated control list.

What you actually need to do (step-by-step)

Use this sequence to operationalize the withdrawn status without creating new risk.

Step 1: Set the authoritative status in your control source of truth

1. Locate 03.14.07 in your control library (spreadsheet, GRC tool, SSP appendix, or policy/control catalog).
2. Set Status = Withdrawn (NIST SP 800-171 Rev. 3) and lock the field so it cannot be changed without review. ¹
3. Add an “Assessment treatment” note: Not applicable due to withdrawal; no implementation/testing required.

Practical tip: If your GRC tool forces an “implemented/not implemented” field, add a third state (“Withdrawn/Removed”) or a compensating “Not applicable” workflow with approvals.

Step 2: Identify and retire “ghost evidence” tied to 03.14.07

1. Search your evidence repository for artifacts labeled “03.14.07.”
2. Re-tag those artifacts to the correct active Rev. 3 requirement(s) if they still support real controls.
3. If the artifacts are only there to satisfy 03.14.07, archive them as historical references and remove them from recurring evidence collection schedules.

This prevents repeated audit churn where teams keep collecting proof for a requirement that no longer exists.

Step 3: Update your SSP/control matrix and POA&M logic

1. In the SSP, mark 03.14.07 as withdrawn and explicitly state “no control required under Rev. 3.” ¹
2. Remove 03.14.07 from POA&M generation rules. A withdrawn requirement should never produce a POA&M item.
3. Confirm your internal test plan excludes 03.14.07 from sampling and walkthroughs.

Step 4: Create a crosswalk note to avoid stakeholder confusion

Write a short crosswalk entry (one paragraph) answering:

• Was 03.14.07 present in our prior baseline?
• If yes, where did the intent go in Rev. 3 (mapped requirement IDs), or is it formally removed with no replacement?
• Who approved the disposition and when?

If you do not have enough information to map it cleanly, document that the requirement is withdrawn in Rev. 3 and that you treat it as out of scope for assessment, pending any customer-specific overlay. ¹

Step 5: Bake it into change control (so it stays fixed)

Add a control-library maintenance procedure:

• Monitor updates to NIST SP 800-171 Rev. 3 sources.
• Review changes and update mappings.
• Re-issue SSP/control matrix versions with change notes.

If you use Daydream to manage requirement libraries and evidence schedules, configure a rule that marks withdrawn items as “non-testable” and prevents them from appearing in evidence requests or auditor dashboards. This is where automation pays off: it eliminates recurring human error and keeps assessment scope clean.

Required evidence and artifacts to retain

Even though the requirement is withdrawn, you still need evidence that your program is correctly governed.

Retain:

• Control library entry for 03.14.07 showing status “Withdrawn” and the date/version reference to Rev. 3. ¹
• SSP excerpt or appendix page where 03.14.07 is marked withdrawn with “no implementation required.” ¹
• Crosswalk/mapping memo (internal) documenting any reassignment of legacy controls/evidence to active requirements.
• Change log for your control set (ticket, approval record, meeting minutes, or GRC workflow history) showing who approved the update.
• Evidence plan update showing 03.14.07 removed from recurring collections.

Common exam/audit questions and hangups

Expect these questions from assessors, primes, or internal audit:

• “Why is 03.14.07 missing from your control implementation narrative?”
• “Your questionnaire response references 03.14.07. Where is the evidence?”
• “Is 03.14.07 ‘Not Implemented’ or ‘Not Applicable’?”
• “Show us how you track NIST SP 800-171 Rev. 3 changes in your SSP.”

Fast answers that work:

• Point to the Rev. 3 excerpt indicating withdrawal and show the SSP/control library marking. ¹
• Demonstrate that withdrawn requirements do not generate POA&Ms or test steps.
• Provide the crosswalk note if someone insists the objective must be covered elsewhere.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it causes pain	Fix
Marking 03.14.07 as “Not Implemented”	Creates a fake gap and may trigger remediation work	Use “Withdrawn” or “Not applicable due to withdrawal,” with approval notes 1
Leaving 03.14.07 in recurring evidence requests	Burns cycles and confuses control owners	Remove from evidence schedules; re-tag artifacts to active requirements
Deleting all references with no trace	Auditors may ask why it disappeared	Keep a controlled record: withdrawn status + change log
Allowing third parties to reintroduce it via templates	Prime/customer templates can be outdated	Maintain a standard response snippet: “Withdrawn in Rev. 3,” with source citation 1
Treating “withdrawn” as “do nothing”	You still need traceability and scope clarity	Update SSP, control matrix, and testing scope explicitly

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat risk here as assessment and contractual risk, not a standalone regulatory penalty model.

Realistic risks for mishandling a withdrawn requirement:

• Assessment delays: time spent reconciling mismatched requirement sets.
• Inaccurate attestations: responses that claim gaps for withdrawn items can weaken your overall compliance narrative.
• Contract friction: primes and customers may question control maturity if your SSP contains outdated references.

Practical execution plan (30/60/90-day)

Avoid calendar promises you cannot keep; use phased outcomes.

First 30 days (Stabilize scope)

• Identify every place 03.14.07 appears (SSP, control matrix, GRC tool, evidence repository, questionnaires).
• Set the official disposition to Withdrawn with an approval record. ¹
• Stop any recurring evidence tasks tied to 03.14.07.

By 60 days (Repair traceability)

• Complete the crosswalk note: map any legacy control intent/evidence to active Rev. 3 requirements or archive as historical.
• Update SSP language and export an assessor-ready control matrix reflecting the withdrawn status. ¹
• Train control owners and proposal/questionnaire teams on the standard response for withdrawn requirements.

By 90 days (Prevent reintroduction)

• Add a control-library maintenance procedure tied to NIST SP 800-171 Rev. 3 updates. ¹
• Implement automated validation in your GRC workflow (or Daydream) to flag withdrawn items and block them from testing/evidence queues.
• Run an internal “dry-run” assessment report to confirm 03.14.07 produces zero findings and zero evidence requests.

Frequently Asked Questions

If 03.14.07 is withdrawn, can an auditor still ask about it?

Yes, they may ask why it is not implemented if they are using an older checklist. Your job is to show it is withdrawn in NIST SP 800-171 Rev. 3 and that your SSP/control library reflects that status. ¹

Should we remove 03.14.07 from our SSP entirely?

Usually keep it as “Withdrawn” in the requirement table or change log if your SSP format supports it. Removing it without a trace creates reconciliation questions during reviews and renewals. ¹

What if a customer or prime contract still references 03.14.07?

Treat it as a contractual clarification issue: respond that the requirement is withdrawn in Rev. 3 and offer to map the underlying intent to your current controls. Keep the communication and mapping note as an artifact. ¹

Do we need a POA&M item for 03.14.07?

No. A withdrawn requirement should not generate a remediation plan because there is no current requirement to satisfy under Rev. 3. Your artifact is the withdrawn disposition and traceability record. ¹

How do we handle legacy evidence tagged to 03.14.07?

Re-tag it to active Rev. 3 requirements if it supports a real control, or archive it as historical. Avoid keeping it in recurring evidence cycles tied to withdrawn items.

What is the fastest way to keep withdrawn requirements from reappearing?

Put your NIST SP 800-171 Rev. 3 library under change control and make “withdrawn” a distinct state in your GRC workflow. If you run Daydream, configure automation to suppress withdrawn requirements from audits, evidence tasks, and dashboards. ¹

Footnotes

1. NIST SP 800-171 Rev. 3